WMSA/HSE - Technical Q & A

  

Q:   Who is responsible for CE Marking?

A:    The responsibility for CE marking will fall on the manufacturer if the manufacturer is EU-based and selling products directly or the manufacturer's agent within the European Union if the manufacturer is based outside of the European Union. Third parties cannot apply the CE marking or make declarations of conformity unless they are responsible for placing the product in the EU.

(Source HSE e mail 18.12.09)

  

Q:    Does CE supersede the requirements of PUWER?

A:    PUWER and the Supply of Machinery (Safety) Regulations complement each other. PUWER 98 places a duty on the user to ensure that any item of equipment complies with any essential health and safety requirements. There are 17 sets of regulations providing these and they are listed in Schedule 1 of PUWER 98. The Supply of Machinery (Safety) Regulations 1992 is by far the most significant. These are known as product legislation. 

Regulation 10 of PUWER 98 requires the user to check that equipment purchased is CE marked and to ask for a copy of the Declaration of Conformity.

However, it should be remembered that having a CE Mark on an item of work equipment is

no guarantee that the essential requirements have been met and the employer must not

think that he has been relieved of any duties to comply with PUWER 98.

(Source HSE e mail 18.12.09)

  

Q:    Having assigned the machine CE on site, is the manufacturer required to perform an EN 60204 electrical installation test?  The machine is tested in Europe prior to disassembly for transport, the machine is then assembled on site and several electrical cables are plugged back in to the appropriate terminals.  Should we do another continuity test on site? 

A:   The electrical supply to the machine should be tested to ensure it complies with BS7671 (or a similar standard) though this may be the responsibility of the building occupier / owner.

We would expect the machine installer to carry out sufficient testing to establish that the safety precautions inherent in the equipment design are satisfactory prior to energisation. For, example if earth bonding between various parts of the machine has been disassembled then reconnected then we believe it would be reasonable to test this to ensure it is satisfactory. This will apply to other aspects but would not necessarily mean a complete retest of the whole machine. Where plug-in connections are used, it is not usual to retest electrical connections every time they are made or removed but this depends on the design and robustness of the plug/socket. 

However, we would suggest that if these connections incorporate safety related control systems then some form of functional testing is carried out.  The range and type of plug connectors available is wide and varied and some are much more robust than others and may incorporate key systems to prevent incorrect insertion - these factors will influence the level of testing required

(Source HSE e mail 9.2.10)